China Exports

China's own export control system — the Export Control Law effective December 2020 and subsequent implementing regulations — restricts exports of dual-use items, military goods, and items related to national security. China has imposed export controls on gallium, germanium, graphite, and rare earth processing technology, directly affecting US manufacturers dependent on these inputs. For US companies exporting to China, BIS license requirements have expanded significantly: the Entity List covers hundreds of Chinese end users, the Military End User rule captures additional entities, and the Advanced Computing rule restricts high-performance chips and related equipment. We cover China's outbound export controls, BIS licensing requirements for exports to China, and how the two regimes interact for dual-use technology transactions.